Category Archive: Compliance

Compliance – That Call We All Fear

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Last week I picked up the phone to call a long-time CS2 client to check in – my latest email to him had bounced back and I wanted to make sure we had his new email address. Instead of his cheerful voice on the other end of the line greeting me with the name of …

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Compliance – Annual Renewals and Annual Amendments

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 Annual Renewals and Annual Amendments – Yes, It’s That Time Again!   It’s hard to believe, but it is time once again to prepare for annual registration renewals and annual amendments. There have also been important changes to the log-in requirements for the IARD and CRD, and ePay has been replaced by E Bill.   …

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Compliance – Suitability Standard

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What is really involved in meeting the “suitability” standard?   Here at CS2 we work with firms of all types and sizes, and frequently we hear a client launch into a passionate condemnation of the “inferior” FINRA suitability standard to which registered representatives are held.  All too often, we learn that they share those opinions …

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What Advisors Should Know About State Long Term Care Partnerships

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We have all heard the horror stories about people whose savings for their children’s college educations and their retirement savings have been wiped out because they did not plan for what would happen if they needed long term care.  Increasingly, we are also hearing about similar situations happening to younger families because one or more …

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Compliance – Rule 3a-4 of the Investment Company Act

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Providing or recommending discretionary management, including model portfolios? Be sure you understand SEC Rule 3a-4 under the Investment Company Act of 1940.   Do you manage client assets on a discretionary basis?  Do you refer clients to a third-party manager that has discretion? Do you or an adviser you recommend trade portfolio models for clients …

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Compliance – New Changes to the ADV Part 1 in the IARD

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The next time you log in to the IARD to complete an amendment, annual or otherwise, you’ll notice some changes to various questions in the system.  (And if, like us, you had draft amendments and applications in the system, you’ll find that no amount of begging, bribery or tantrum-throwing will resurrect those drafts, which were …

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